Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Rectification u/s 154 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
Rectification u/s 154 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
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